Zane D. and Debbie L. Worman - Page 3




                                        - 2 -                                         
          other court, and this opinion shall not be treated as precedent             
          for any other case.                                                         
               This matter is before the Court on respondent’s Motion To              
          Dismiss For Lack Of Jurisdiction, filed June 1, 2007, and                   
          supplemented June 13, 2007.  In his motion, respondent moves to             
          dismiss this case for lack of jurisdiction principally on the               
          ground that “no Notice of Determination Concerning Collection               
          Actions Under Section 6320 and/or Section 6330, as authorized by            
          I.R.C. § 6320 and required by I.R.C. § 6330(d) to form the basis            
          for a petition to this Court, has been sent to petitioners with             
          respect to taxable years 1995, 1998, 2002 and 2003”.  Respondent            
          also moves to dismiss on the ground that “as to the IRS filed               
          Notice of Federal Tax Lien which is attached to the petition,               
          said lien was released on February 14, 2007, and the liability              
          fully paid”.  For reasons discussed hereinafter, we shall grant             
          respondent’s motion, as supplemented, in that we shall dismiss              
          this case for lack of jurisdiction on the ground that no notice             
          of determination was sent to petitioners by respondent’s Office             
          of Appeals for any of the taxable years in issue.                           
                                     Background                                       
               At the time that the petition was filed, Zane D. Worman and            
          Debbie L. Worman (petitioners) resided in Gillette, Wyoming.                
               For 1995, 1998, 2002, and 2003, the taxable years in issue,            
          petitioners filed Federal income tax returns.  Although                     







Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next 

Last modified: November 10, 2007